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At the time of filing the petition in their case,
petitioners S.K. Johnston III (S.K. Johnston) and Julie N. Boyle,
f.k.a. Julie N. Johnston (Julie Boyle), resided in Atlanta,
Georgia, and Camden, South Carolina, respectively.5 At the time
of filing the petition in his case, S.K. Johnston, Jr.
(petitioner), resided in Atlanta, Georgia. At the time of filing
the petition in their case, Gillian S. Johnston (Gillian
Johnston) and petitioner (collectively the Johnstons) resided in
McDonald, Tennessee, and Atlanta, Georgia, respectively.6 For
convenience, we present a general background section and combine
our findings of fact with our opinion under each separate issue.
General Background
Petitioners' Activities
There are four activities at issue in the instant case,
which are conducted in three primary locations. The first
activity is Bendabout Farm (Bendabout or the farm), which is
located approximately 10 miles east of Chattanooga, Tennessee.
The second activity is Flying H Ranch (Flying H or the ranch),
which is located on the eastern slope of the Bighorn Mountains in
north-central Wyoming near the Montana border. The third
activity is Bendabout Polo Sales and Management Co. (BPS),
conducted by a partnership of which petitioner owns 75 percent,
5 S.K. Johnston and Julie Boyle were married and filed joint
returns for 1987, 1988, and 1989.
6 Petitioner and Gillian Johnston filed joint returns for 1987
and 1989, and separate returns for 1988.
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